PARTNERSHIPS usually designate one of the partners as the point of contact with the IRS in any tax audits.
That partner is called the “tax matters partner.” Only general partners — not limited partners — can act as tax matters partners since the IRS wants someone who can bind the partnership.
The IRS said in August that a partnership whose sole general partner is a “disregarded” limited liability company could only name the disregarded LLC as its tax matters partner, notwithstanding that the LLC
is not considered to exist for tax purposes. The ruling is a breach in the rule that disregarded entities are treated as if they do not exist. It is Revenue Ruling 2004-88.